Revenue Cycle

Providers take note: CMS releases revised ABN form

Medicare Update for CAHs, August 10, 2011

On a July 13 Hospital Open Door Forum call, CMS announced the release of its revised advanced beneficiary notice (ABN) form, which requires mandatory usage on and after November 1, 2011. While the changes to the form are related to its format, it could create real problems for providers that do not adhere to this deadline.

“I was surprised that this form was announced a little under the radar,” says Debbie Mackaman, RHIA, CHCO, regulatory specialist for HCPro, Inc. “There is a notice on CMS’ Beneficiary Notice Initiative web page but if you weren’t out there looking for something or heard it on the ODF, you probably would not have known it was changed.”

An ABN must be issued when a provider believes that Medicare might not pay for an item or service that Medicare usually covers, because it is not considered medically reasonable and necessary for this patient in this particular instance. This instance of noncoverage is also known as “limitation on liability (LOL)” and LOL also applies when services fall into the following categories:

  • The services are screening services that are being provided more frequently than Medicare provides a benefit for; or
  • It is not considered medically reasonable and necessary for this patient in this particular instance.

If a provider does not deliver a valid ABN to the beneficiary when required by statute, then the beneficiary is not held accountable for the services, and the provider may be held financially liable, according to CMS. Here is where usage of the revised ABN form comes into focus. After November 1, 2011, all ABNs with the release date of 3/2008 will be considered invalid, and thus the patient will be protected by limitation on liability and not held liable for the services.

In this situation, the hospital or provider will be held financially responsible for any services rendered, placing an onus on providers to be aware of the new CMS form. CAHs should start now to gather up on the current ABN forms from their various locations, to replace them with the new form, according to Mackaman.

“Since the only changes that were made were formatting in nature, there is no need for training; however, this would be a good time to review your medical necessity screening procedures with staff,” Mackaman says. “Also, make sure that your information system vendor is aware of the change and that their system will be able to accommodate the change prior to the mandatory date of November 1, 2011.”

Most Popular